ASME Interpretations have been extensively cited across a large number of articles on this website to establish a point. The Interpretations published every year bear the sanctity of the respective Committee’s consideration, and are as good as the Code itself. This article is a short commentary representing this blog’s views regarding various aspects of ASME Interpretations.
The article tries to imagine the workings of the Committees that issue these interpretations. A few examples of cases where the ASME has reconsidered its earlier stance have been showed. A few pieces of trivia relating to the interpretations can be found in the article, which some people might find interesting.
Does ASME reconsider Interpretations?
ASME is a body of highly learned people, and they rarely make mistakes. However, they are human beings too, and like all other humans they may err too. Plenty of practical experience forms the basis for framing the stipulations of the Code. The Code is after all only a set of rules formed as a result of the experience gained through actual real world rigorous work by a set of human beings.
But Code has been in existence for several decades now. The people running the ASME today are obviously not the same set of people who first wrote the Section IX. The people who wrote the first edition of Section IX must have, through the wisdom gained in the field of welding, framed the rules enshrined in first edition.
After spending perhaps 25-30 years in ASME, they would have retired. The people in charge of Section IX today, should ideally have the same understanding as the original authors did. However, do they?
Well, the ASME BPVC is an objectively written Code that gives little room for ambiguity. It is hard to go wrong. Plus, periodically, ASME issues Interpretations that bring more clarity to various issues inquired by users of the Code. The replies to these Interpretations serves as a useful compass for the present committees as well as the users even several decades down the line.
Now, Code only tells the ‘what’ of the rules, it rarely tells the ‘why’ behind a rule. We ordinary engineers develop our own understanding regarding the ‘why’, by combining our own experience and common sense.
Sometimes this understanding might be consistent with the persons who first framed the rule, at other times it might be at variance. It is all fine as long as we are consistent with Code regarding the ‘what’.
But the people in charge of Section IX today in ASME must know the ‘why’ too, and that too with a high degree of precision. How do the people in today’s committee know that they have the same understanding behind the ‘why’ of a rule as the original authors did?
Well I guess if you spend a long time among the Codes, you develop a philosophy that is largely consistent with the original thought behind the Code. Of course, sometimes it would vary. The understanding evolves with time, influenced by new data, new research. The Codes get revised every two years to incorporate the evolved understanding, and to rectify the rare errors.
Examples Of Reconsidered Interpretations
Coming back to the question in title, does ASME reconsider Interpretations?
We know that they are only human, it would be completely understandable if they often made mistakes. It is hardly a matter of surprise. I know of only a handful of instances of ASME reconsidering its own Interpretation.
IX-78-05 was issued in January 1978, and a correction to the original interpretation was issued in April, 1978 with a completely opposite understanding, while acknowledging that the matter had been further considered, and correction had been sent to inquirer. Another similar example is IX-78-24.
Another such example was in the form of the Interpretation IX-98-20. The fascinating thing about this one is that, as per the version of Interpretation available in ASME’s website’s database, the reconsidered Interpretation IX-98-20R was issued on the same day!
Perhaps they would have ruled on the matter in one way in the morning, but would have realized their folly during lunch, and would have corrected their error during the post lunch session!
Other such examples, where the reconsidered Interpretation and the original Interpretation show the same date of issue, are IX-89-100 (and IX-89-100R), and IX-98-20 (and IX-98-20R).
Error In Naming Scheme
Another example of a reconsidered interpretation, a recent one, is IX-18-04. This interpretation was issued in November 2015. When one has gone through a good number of Interpretations, it is easy to recognize the naming scheme of these Interpretations.
The first two digits represent the Section number (for example, ‘IX’ represents Section IX), the next two digits represent the year of issue of Interpretation, and the last two digits are a running serial number.
In IX-18-04, issued on 16.11.2015, note that the middle two digits in this Interpretation number do not represent the year of issue, which is odd. It is apparent that this was plainly a typographical error, since I have never come across this kind of deviation ANY other time.
Three years later, when the interpretations for year 2018 were issued, ASME was careful not to use the number IX-18-04 again. This is verifiable on the ASME’s website on ASME Interpretations Database page.
This interpretation was reissued in 2017, with a different Interpretation number IX-17-88, with a revised understanding. Note that the examples cited in previous paragraphs were reissued with the same Interpretation number with a suffix ‘R’ at the last of the same number. However, in this case – the number of revised Interpretation is totally different from the initial one.
Revision In Just One Word
Sometimes an Interpretation is revised with the deletion of just one or two words. There have been cases when just one word slightly and subtly alters the meaning of the text. There are several examples of this. One such case is IX-16-15 (revised Interpretation is IX-17-58), in which just a couple of words have been corrected in the revised Interpretation.
It is visible that the Committee wants to be accurate, and wants to leave no room for ambiguity, which is admirable.
Some other examples of reconsidered Interpretations are IX-83-140 (reconsidered version in IX-83-140R) etc.
It must be said that considering the amount of subject matter involved, the BPVC is a document with incredibly low number of errors/inconsistencies. It is a precisely written document, and is a authoritative guide on the matter it addresses.
What is Errata?
Sometimes mistakes are made by the committee not because of a difference in understanding, but by plain oversight. Such errors may be grammatical errors or typographical errors. ASME possesses a mechanism by the name of ‘Errata’ to correct such errors.
As the name indicates, this mechanism informs whoever concerned about the errors that have been recognized and acknowledged by the committee. The Errata are posted on ASME’s website whenever they are found, and the corrections are incorporated in the next edition of the Code. The link to the errata page on ASME’s website is as below:
http://www.asme.org/kb/standards//publications/bpvc-resources
Recently I came across an Interpretation which had contained a typographical error. The Interpretation IX-07-07 was issued in 2008, with the error. The error was in total in just one word. But one word made all the difference to the intent of the Interpretation.
ASME recognized the mistake, and republished the Interpretation the next year in 2009 with a new Interpretation number IX-07-07E, with the suffix ‘E’ indicating that the Interpretation is an ‘errata’.
What Is An Intent Interpretation?
Code Interpretations are an instrument of obtaining the committee’s clarification on the meaning of the existing requirements, whenever there is an ambiguity on a matter or conflicting requirements are conveyed. Interpretations normally do not introduce new requirements.
Sometimes it may so happen that during the course of deliberations on an inquiry asked in an Interpretation, the committee may feel the need to revise a requirement. The existing requirement may be conflicting, ambiguous, or plainly incorrect. The committee may then decide to revise the Code to reflect the correct requirement. However the revision can be incorporated in the body of the Code only in the next edition!
An intent interpretation is the mechanism to convey revision of the code for the interim, till the revision can be formally incorporated in the next edition. Intent Interpretations usually appear with the words ‘intent interpretation’ in the Subject Description of an Interpretation.
How Is An Intent Interpretation Different From Code Case?
A Code Case contains an alternative or addition to the code, and not a revision to the code. The commonly used applications of Code Cases have been explained at the beginning of the Code, under the title “SUBMITTAL OF TECHNICAL INQUIRIES TO THE BOILER AND PRESSURE VESSEL STANDARDS COMMITTEES”.
Two Interpretations Addressing Same Subject Matter
Another amusing case is when two different Interpretations issued in the same year addressed exactly the same matter. The entire content of both Interpretations was identical, including question and answer. The Interpretations are IX-89-75 and IX-89-78.
Another case where the wordings are different, but the intent conveyed through two Interpretations is same, is found in the case of IX-89-86 and IX-89-96. Interestingly, both these were issued in the same year too.
Another similar case is IX-92-70 and its revised version IX-92-70R, issued 7 years later to the date of issue of the original Interpretation. In the revised Interpretation, the content of question and answer is identical, except that a note has been added at the end of the Interpretation, in the revised version. The note explains meaning of a term used in the Interpretation.
Whether the Committee took this up suo motu, or someone prompted it to, is of course not known to us. But it interesting that a whole new Interpretation has been issued, just to prevent one term in a 7 year old Interpretation from being misunderstood.
A Possible Error In Interpretation
Another occasion where i think the Code made a mistake, but did not acknowledge or correct subsequently, was in Interpretation IX-89-47. The question presented the following situation.
A welder welds his performance qualification test coupon with two electrodes. One is a F number 3 electrode, another is a F number 4 electrode. He deposits 0.125 in. thickness with the F number 3 electrode, and 0.75 in. With the F number 4 electrode. Is it required to record the thicknesses deposited by the two electrodes separately in the welder qualification record?
The reply was given as No. Meaning that it is not necessary to record the individual thicknesses deposited with the two electrodes, having different F numbers, in the WPQ record.
I believe the reply given is wrong. F number is an essential variable, and so is thickness. As per the rules of the Code, this welder can deposit up to a maximum of 0.25 inches using a F number 3 electrode, and can deposit up to a maximum of 1.5 inches using a F number 4 electrode.
If the individual thickness deposited with each electrode is not recorded, how would his qualified range for thickness using each F number electrodes be reckoned?
Does Not Present The Full Picture
Sometimes, the answer given in the interpretation is correct, but does not present the full picture. Consider the following question that got asked in interpretation IX-17-63:
“Background: A welder is qualified on P-No. 8 pipe using GTAW with inert gas backing.
Question: May the welder weld P-No. 1 material without inert gas backing?”
Now deletion of gas backing is an essential variable for performance qualification with GTAW process. However, QW-408.8 allows that requalification is not needed when welding a single welded butt joint with a backing strip or a double welded butt joint or a fillet weld. Further, this exemption does not apply to titanium and zirconium alloys.
This exemption means that the welder IS permitted to weld without backing gas, albeit only under certain conditions. The answer to the above question was given as a brief ‘No’. This answer clearly does not present the whole picture.
Consider another case, question 1 in interpretation IX-86-24. The premise of the question is this: a welder failed to pass the renewal of qualification test, per QW-322. Does this failure constitute a ‘specific reason’ (QW-322) to doubt his ability? The answer given is a simple ‘No’.
What the committee here, in all likelihood, intends is that such a failure does not necessarily constitute ‘specific reason’ to doubt his ability.
The fact of the matter is that the Section IX does not establish criteria/ grounds for what constitutes this specific reason. Establishing this specific reason has been left to the judgment of manufacturer/ inspector.
So, the failure described above may constitute a specific reason, based on the wisdom of inspector. The reply given to this interpretation does not present this picture, and is therefore incomplete. In other words, it does not present the full picture.
Likewise, there are several examples of interpretations involving F-numbers, that are not incorrect per se; however, the reply given by the committee does not present a full picture.
Are All Enquiries Responded To?
Another interesting thing about Interpretations is that the inquiries received from world over are taken up for consideration only on merit of the question. All inquiries are not taken up for consideration by the Committee. Only the inquiry submittals that meet the requirements for submittal are taken up for consideration.
There are elaborate mechanisms available to filter in inquiries which are really deserving of Committee’s attention. The idea is to keep out frivolous, repetitive, confirmatory inquiries. In fact, the Inquiry Submittal Form on the ASME’s website lays out a few conditions upfront, before the inquirer.
The requirements laid out very reasonable and justifiable conditions. For actual consideration of the inquiries, there is a clearly delineated process of evaluation involving ballots at different Committee levels before the final answer is issued out.
With such an elaborate system in place to filter out inquiries that do not meet submittal requirements, it is surprising sometimes to come across Interpretations which are simply confirmations of what is clearly spelt out in Section IX.
There are scores of such examples. A few are IX-78-33, IX-78-65, IX-79-44, IX-83-98, IX-16-04, IX-18-17, IX-19-25, IX-18-18, IX-18-19, etc.
One might think that in the early years when Section IX was still new to the world, the Committee would entertain such inquiries to establish the philosophy of Code more firmly. But that is not the situation today. A few of the examples cited above are from the recent few years.
So these were a few observations that I had on the subject of ASME Interpretations, after having used them extensively over the last few years in my role as a welding engineer. Would you like to add something?
Please do leave your thoughts in the comments section below.